From The FAA: Paint a Picture

Flying in the cockpit of a 737 at 34,000 feet affords one a humbling view; a picture the greatest artist in the world could never do justice to in any painting. It’s ironic because as I oversee the Earth below, I am reminded that as a Federal Aviation Administration (FAA) inspector it is my job to oversee the airworthiness side of the aviation industry, at least the part that exists in the New England (Eastern) Region. But who keeps a close watch over the Flight Standards division of the FAA? The answer is simple: I do.

Alright, I just admitted to working for the FAA and being responsible for watching over Flight Standards; hmm, that sounds contradictory and slightly nepotistic. Allow me to paint a picture for you (or in my case, paint-by-number) that better elaborates.

Larger operators like your Part 121 airlines or sizable Part 135 or 145 certificates, self-evaluate as part of their normal order of business. Quality control is built into the operator’s maintenance program to allow the operator to self-police itself; to discover problems before the customer or the FAA can. Often times, when the operator follows the quality control program as laid out, the operator makes the fix and improves the way a product or service is delivered.

Flight Standards evaluation

It’s the same with the Flight Standards division of the FAA; we, too, have a quality control mechanism in place that allows us to self-evaluate, determine fixes, and apply improvements, then assure the enhancements work. The Flight Standards Evaluation Program (FSEP) is the audit system Flight Standards uses to approach the individual offices with an unbiased yet experienced view into how the Administration’s policies are being employed. It is through this impartial snapshot taken that Flight Standards can stand back to see what is really going on within.

Based on ICAO

The FSEP was created to be and is currently an International Organization for Standardization (ISO, and no, the acronym shouldn’t be IOS) 9001:2008 internal audit process; it is based on the requirements dictated by the International Civil Aviation Organization (ICAO), a consortium of countries whose representatives speak for the aviation safety disciplines of the region they act for. ICAO has regional offices in Asia, South America, Europe, Africa, the Middle East, and Central America; it represents the joint standards of governments across the seven continents with the mission to make aviation safety a worldwide requisite built upon the needs and direction provided by its members. Those who believe that ICAO was borne for a global economy would be incorrect; ICAO is the latest stage of evolution from the Chicago Convention of 1944, which was organized in the waning days of World War II.

The FSEP audit evolved as a result of a 1999 recommendation from ICAO, that the FAA (and other complying organizations) “should introduce a quality audit system that has terms of reference to audit all regional offices and their suboffices.” It points out that the “auditors should be independent of the region audited and focused on the implementation and consistent application” of the regulations, which I will clarify later. Lastly, “the reports and findings should be analyzed by a central body;” this concept, again, will be clarified later in this article.

Quality audit system

The quality audit system is the responsibility of the AFS-040 division, the central body within the Flight Standards office of the FAA. The Flight Standards Director charges them to oversee the auditing of the Flight Standards’ offices, which include: Flight Standards District Office (FSDO), Certificate Management Office (CMO), Aircraft Evaluation Group (AEG), International Field Office (IFO), Regional Office (RO), and even Headquarters. Each separate office is audited on a three-year schedule, meaning that each office within Flight Standards’ jurisdiction, that includes offices in Europe and Asia, receives an in-depth audit every three years to assure the Director that Flight Standards is following the procedures, policies, and guidance of Flight Standards. Each office has been audited at least twice.

Job aid tools

Audits vary according to the type of Flight Standards office being visited. Job aid tools are used by the auditors as they visit a site; the audit is streamlined by concentrating on the office’s functions, e.g. a FSDO is audited for the Part 135 or 145 certificates it oversees, whereupon an AEG does not oversee such certificates. These job aids were designed and written by AFS-040 members who come from all different disciplines of the FAA; they brought their experience to the division from both Operations (flight) and Airworthiness (maintenance). The layout of the job aids allows the auditor to concentrate on the office’s various functions; the job aid puts focus items in question form which the auditor answers by reviewing, e.g. training records, designee files, and/or individual operator maintenance programs.

Each question directs the auditor to view how Flight Standards’ policies are being followed in the office. The means to accomplish this is by taking a representative sample of the office’s certificate holders/designees and putting them through the job aids’ paces; the auditor gets to see if the policies are being applied consistently throughout that particular office. Interpretation of each question is addressed with policy references printed next to the question on the job aid to remove doubt as to the intent of the question. As the audits continue through the year, the job aids are revised to the changes in industry and policy; they are modified by input from auditor and audited alike.

The audit team

The audit team is gathered from an audit pool of about 100 auditors; a team consists of four auditor members: two from Airworthiness and two from Operations. This number may change if the audited office’s size is too small for a four-person team. These team members may not work in the AFS-040 division, but come from all regions of the FAA.

The teams work under the direction of the team leader. The key to remaining unbiased is that each member, whether team member or team leader, is from a different region from the office being audited, e.g. since I am from the New England region I can only audit offices outside the jurisdiction of my region.

Each member is trained by AFS-040; they receive orientation and FSEP audit training before being added to the pool. A team member is first assigned with a trainer who walks him/her through the first audit to familiarize them with the procedures. The team leaders also receive ISO Auditor Lead training and are supervised through several audits before taking the reins themselves.

Teams are trained to not only look for systemic weaknesses for correction, but they identify best practices for other offices and regions to benefit from; most offices often “build better mousetraps,” so FSEP shares these ideas throughout the system. It is often through this identification of best practices that the best improvements are made. I have several times brought ideas from other offices back and improved how my office does business.

Addressing concerns

Consequently when the audit shows that the implementation and consistent application of the regulations is in dispute, the FSEP takes a two-stage approach. First, the question is put to the office’s point of contact (POC). The POC has this opportunity to find the information addressing the auditor’s concern.

However, if the POC cannot answer the question the second approach is to generate a nonconforming product record (NCR), a corrective action request (CAR), or a preventive action request (PAR). The office may need to produce a NCR or PAR, but the audit team only produces a CAR.

• A NCR is a one-time failure to fulfill a requirement that does not represent a trend. The NCR is reported and fixed, often before the audit closes.

• A CAR is a nonconformance that is either systemic or has a broad effect. The CAR is issued to both fix the problem and assure the office managers put steps in place to prevent any re-occurrence. A CAR is monitored by AFS-040 from its inception to its conclusion with a due date attached for closing.

• The PAR recognizes evidence of process hazards with the anticipation of resulting problems. Although the problem hasn’t yet occurred, evidence suggests a service or product will be affected if not prevented. Again, a PAR is tracked by AFS-040 from beginning to end.

The big picture

AFS-040 regularly reports the audit data to the Director; the trends are summarized and the Director is given the big picture. The audit program, like the offices they assess, is constantly changing to meet the needs of the FAA and the flying public.
The ISO audit process is a tool the Flight Standards division of the FAA uses to get a picture of how the organization is doing and which direction they need to take, similar to the many certificate holders that self-evaluate. This may not be the legendary “big picture,” but instead a snapshot; an X-ray into the health of Flight Standards to determine how to make it stronger by improving on what is within. AMT

Stephen Carbone is an aviation industry veteran of 28 years. He worked for FedEx for 19 years, where he began as a mechanic and eventually finished as a supervisor for line maintenance in Newark, NJ. He worked with the NTSB as the sole A&P certified accident investigator, and he taught at the NTSB Academy and at the Pax River Naval base education center in Maryland. Stephen joined the FAA in 2004 where he was first assigned to the Air Carrier Maintenance Branch in Washington, D.C., and he worked with the late Bill O’Brien. In 2006 he transferred to the Boston regional office in the Flight Standards Airworthiness Technical Branch. He holds a master’s degree in aviation safety systems.